Foley Automotive Update

Analyse door Julie Dautermann, analist Concurrentie-informatie

Foley is er om u te helpen bij alle aspecten van het heroverwegen van uw bedrijfsstrategieën, investeringen, partnerschappen en technologie voor de lange termijn. Neem contact op met de auteurs, uw Foley-relatiepartner of ons Automotive Team voor meer informatie.

Belangrijkste ontwikkelingen

Foley & Lardner partners Vanessa Miller and Nicholas Ellis assessed the industry implications of GM’s new purchase order “Program Extension Clause.”
Foley & Lardner partners Vanessa Miller and Alejandro Gómez Strozzi led discussions at the 23rd International Congress of the Automotive Industry in Mexico (CIIAM 2025) regarding legal and regulatory shifts shaping regional trade integration.
Foley & Lardner’s “Made in America: End-to-End Guide to Developing Your U.S. Manufacturing Footprint” series delves into the critical decisions U.S. manufacturers face as they rethink where and how they build. The most recent article in the series is Pricing Stability and Supply Continuity: Strategic Contracting for Reshoring. Subscribe here to receive updates when new articles in this series are published.
Foley & Lardner partner Lynn Gandhi discussed state and local tax incentives for U.S. manufacturing operations in an audio interview with GlobalAutoIndustry.com.
Foley & Lardner provided an update for companies doing business in Mexico regarding supply chain compliance programs amid growing risks from the Treasury Department’s heightened enforcement priorities.
Foley & Lardner partner Christopher Swift commented on the U.S. Supreme Court’s consideration of the executive branch’s authority to impose tariffs in the Supply Chain Dive article, “White House asks Supreme Court to uphold Trump’s tariff powers.”
Automotive News provided an overview of the impact of the federal government shutdown on the auto industry.
Auto suppliers are encountering a widening financial divide and heightened market pressures due to tariffs and the shift away from vehicle electrification, according to analysis from Plante Moran.
The Trump administration plans to impose a 25% import tariff on all medium and heavy trucks beginning November 1, 2025 in response to a Section 232 national security investigation. At the time of this newsletter publication, details have not been provided regarding exemptions or whether the tariff includes truck parts. Preliminary estimates suggest the tariffs could affect up to $15 billion of truck imports.
The National Association of Manufacturers estimated the Commerce Department’s Section 232 national security investigation of robotics and industrial machinery imports could affect roughly half a trillion dollars in manufacturing equipment and inputs. Public comments are due by October 17, 2025, according to the Federal Register Notice. The Commerce Department has contingency plans that suggest investigations into certain imports that affect national security may continue during the government shutdown.
The European Commission proposed doubling steel tariffs to 50%, and reducing tariff-free import volumes by 47% to 18.3 million tons a year. The previously announced U.S. – EU framework trade agreement lowered tariffs on auto imports from the European Union to 15%. However, certain trade issues that include steel and aluminum tariffs remain open to further negotiations.
Third-quarter 2025 U.S. new light-vehicle sales were up 15.9% YOY for Toyota, 13% for Hyundai, 8.2% for Ford, 8% for GM, 6% for Stellantis, and 5.3% for Nissan. Sales declined 6% for Volkswagen and 2% for Honda.
U.S. new vehicle sales in September 2025 rose 3.5% YOY and reached a SAAR of 16.4 million units, according to estimates from the National Automobile Dealers Association.
Full-year 2025 U.S. vehicle sales are projected to reach approximately 16 million units, according to S&P Global Mobility.
China announced new restrictions on exports of rare earths and other critical materials due to national security concerns. Foreign entities will need to obtain a license from Beijing to export certain products “containing over 0.1% of domestically-sourced rare earths, or manufactured using China’s extraction, refining, magnet-making or recycling technology.”

OEMS/Suppliers

The Wall Street Journal reports that a plant fire at a significant aluminum supplier to Ford could disrupt business “for months” as the company provides an estimated 40% of aluminum sheet used in the auto industry. Ford is reported to be temporarily halting production of the F-150 Lightning electric pickup in Dearborn, Michigan, due to the fire.
Bankruptcies among German suppliers are on track to be 30% higher in 2025 compared to last year, amid challenges that include reduced demand, higher operational costs and increased competition from Chinese automakers. Germany’s auto industry could lose up to 190,000 jobs by 2035, according to estimates from the German Association of the Automotive Industry (VDA).
The European Association of Automotive Suppliers (CLEPA) urged policymakers to establish minimum content requirements for the components used in vehicles manufactured in the EU.
Automotive News provided an update on automakers’ exposure to bankrupt aftermarket auto parts supplier First Brands Group.
Jaguar Land Rover is reported to be considering a supplier loan of up to £500 million ($674 million) to support its supply chain after a cyberattack halted the automaker’s production.
ArcelorMittal announced plans to establish a new 154,000 sq. ft. auto components plant in Ingersoll, Ontario.
GM has spent more on federal government lobbying this year than any company other than Meta.
Hyundai has maintained its commitment to $26 billion in U.S. investments and increasing American production. Hyundai and Kia’s combined U.S. market share was approximately 11% as of mid-2025.
Volvo plans to increase production at its Ridgeville, South Carolina plant, beginning with its popular XC60 SUV in late 2026 and a new hybrid vehicle by 2030.

Markttrends en regelgeving

Automakers may reduce emphasis on lightweighting in response to tariff costs and the easing of restrictions for fuel economy and emissions standards.
Analysis from Edmunds indicated 19.1% of new vehicle consumers in the third quarter of 2025 committed to monthly payments of $1,000 or more, and 22% of financed new-car purchases had loan durations of seven years or longer. In addition, the average down payment for a new vehicle in Q3 2025 fell to $6,020, representing the lowest level in nearly four years.
Automakers may be impacted by higher platinum prices, which have risen by more than 85% in 2025.
An interim final rule from the Commerce Department will extend certain export controls to subsidiaries that are at least 50% owned by companies named to the Specially Designed Nationals and Blocked Persons List.
New-car registrations in Europe increased 4.5% YOY in August and registrations were down by 0.1% for the first eight months of 2025, according to data from the European Automobile Manufacturers’ Association (ACEA) released on September 25. Hybrid-electric models accounted for 34.7% of the total EU market in the first eight months of 2025, while battery-electric vehicles (BEVs) represented 15.8% and plug-in-hybrid electric vehicles (PHEVs) were 8.8% of the market.
The European Commission plans to review its zero CO2 emissions targets for new vehicles by the end of 2025, in response to automakers’ concerns over the feasibility of complying with the regulations.

Autonome technologieën en voertuigsoftware

A number of major automakers and higher revenue suppliers are urging the automotive supply base to adopt artificial intelligence technologies to help improve efficiencies.
Automotive industry managers expect advanced technologies to deliver manufacturing efficiency gains of 10% by 2028 and 30% by 2030, according to a Bain & Company survey.
A recent survey from RunSafe Security found less than 19% of surveyed connected car drivers were very confident their vehicle is protected from cyberattacks, and 87% said cybersecurity affects vehicle purchase decisions.
Qualcomm and BMW jointly developed an automated driving system that will debut on the BMW iX3 electric SUV. The Snapdragon Ride Pilot Automated Driving System was designed to be licensed to other automakers and supports Level 2+ highway and urban navigation on autopilot capabilities.
Valeo had roughly $10.6 billion in orders for products used in software-defined vehicles in the last three years.
Mercedes-Benz spun out its Silicon Valley chip development group into a new company, Athos Silicon, that will develop advanced technology in areas that include autonomous vehicles.
Self-driving truck developer Kodiak AI began public trading following its merger with special-purpose acquisition company Ares Acquisition Corp. II.
Amazon’s Zoox is seeking approval from the National Highway Traffic Safety Administration to deploy up to 2,500 robotaxis on U.S. roads.
China’s Hesai Technology announced it is the first lidar company worldwide to exceed one million units in annual production.

Hybrid and Electric Vehicles

Third-quarter 2025 BEV sales represented a record-high 10% of total new vehicle sales, as consumers rushed to get the $7,500 federal EV tax credit that expired September 30.
Tesla delivered a record-high 497,099 vehicles globally in the third quarter of 2025, representing an increase of 7% YOY. This week Tesla debuted Model Y and Model 3 trims that are priced under $40,000.
Ford CEO Jim Farley predicted U.S. BEV market share could fall to 5% of total new light-vehicle sales in the coming months. Dealerships were estimated to have roughly 134,000 unsold EVs nationwide at the end of September.
Rivian’s third-quarter 2025 U.S. deliveries rose 32% YOY to over 13,000 EVs. The company narrowed its 2025 delivery guidance to 41,500 to 43,500 vehicles.
GM, Ford, and Hyundai are among the automakers that plan to extend discounts on certain EV models following the expiration of the $7,500 federal tax credit.
Reuters reports the Department of Energy is considering revoking nearly $1.1 billion in awarded grants for GM and Stellantis to retool certain plants to produce EVs or EV components. According to the article, the potential cancelation of the awards was attributed to the government shutdown.
NextStar Energy, a joint venture between LG Energy Solution and Stellantis, finished construction of its $5 billion EV battery plant in Windsor, Ontario.
The DOE will invest 5% equity stakes in Lithium Americas, as well as the company’s Thacker Pass joint venture lithium mining project with GM in Nevada. This deal revises a Biden-era federal loan that is now valued at $2.3 billion.
Automotive News provided an updated list of canceled or postponed EV models in the U.S. Most recently, Honda canceled all future production of its 2026 all-electric Acura ZDX built at GM’s Spring Hill, Tennessee plant to “better align our product portfolio” with consumer demand.
China will require automakers to obtain export licenses for EVs beginning in 2026, as part of an effort to reduce price wars and curtail the export of low-quality products.
BYD’s global sales fell 5.5% YOY in September, representing the automaker’s first monthly sales decline since February 2024.
The number of EV fast-charging ports in the U.S. surpassed 60,000 in August 2025, representing an increase of more than 80% in two years.
San Francisco-based EV Realty raised $75 million in funding from private equity investor NGP. The funding will support projects that include a 76-stall fast-charging facility for commercial fleets in San Bernardino, CA.